Index Home Join IPCC

IPCC Policy Statement on Wind Energy Developments, August 2001

1 Introduction
In 1998 the Irish Peatland Conservation Council (IPCC) organised a meeting with other environmental groups to voice our concerns over windfarm development in sensitive peatland areas. A joint document was compiled by Ireland's leading environmental NGOs. Since then, this document has represented the policy of IPCC towards wind energy development in Ireland.

With the increase in the number of windfarm developments proposed for upland peatland areas IPCC decided to update this policy statement to account for the latest circumstances. There is also an increased public concern over the possible impacts of windfarm development on upland areas. IPCC hopes that this policy statement will be informative and useful to developers, local authorities, government departments and the general public.

1.1 Wind Energy Strategy In Ireland
Wind energy development is relatively new in Ireland, particularly when compared to other EU states such as Denmark and Germany. The first commercial wind farm was commissioned and supplying energy to the national grid in 1992. It remained the only wind farm supplying electricity to the network until 1997 when a further 6 were commissioned. At present there are 19 in operation in the Republic of Ireland with a further 8 in operation in Northern Ireland.

The combined installed capacity is 155 Megawatts which represents 2.3% of Ireland's total installed energy generating capacity. In terms of electricity produced, the contribution of wind energy currently represents 1%. Government targets for renewable energy have increased dramatically to 500MW of energy to be installed between 2000 and 2005, the majority of this is to come from wind energy. By 2010 wind energy is expected to account for 10.7% of total installed electricity generating capacity. The key driver to these targets is Ireland's commitment to limit our growth in greenhouse gas emissions to 13% from 1990 to 2010.

1.2 IPCC Support of Renewable Wind Energy
IPCC recognise the fundamental importance of increasing Ireland's renewable energy sector as part of international efforts to combat climate change and reduce dependency on fossil fuels.

We further recognise that wind energy is a clean renewable, non-polluting source of energy, which is deserving of government support when taking into account the external environmental costs posed by electricity generated from fossil fuel sources.

However, we are concerned that in the absence of a clear strategy governing wind farm developments and their environmental impacts, their full benefits may not be realised.

1.3 The Principal Issue
The development of windfarms should be an environmental benefit and has the ability to assist in improving the quality of our environment by halting the abstraction of non-renewable resources such as peat and oil and, as a by-product prevent the further pollution of the environment from burning these valuable resources for electricity generation. Unfortunately these benefits are accompanied by environmental costs. To maximise the environmental benefits of wind energy it is necessary to keep the environmental costs to a minimum. This can easily be done by locating windfarms outside of areas of high conservation value.

1.4 Impacts of Windfarms on Upland Bogs and Heaths
There has been little scientific work done on the impacts caused to Blanket Bog and Heath habitats by windfarm developments. It is known however, that they may impact severely on the functioning of an intact peatland system. It is a widely accepted conservation policy within blanket bog areas to avoid any fragmentation of the extensive blanket bog with developments, as these impact adversely on the wildlife, eco-hydrology and physical characteristics of the peatland ecosystem (Douglas 1998). The laying of turbine foundations cause drying out and compaction of peat accompanied by habitat destruction. The infrastructure (servicing roads, power lines etc.) that must be installed causes further damage. The work carried out during construction cause major destruction to the habitats that may be irreversible. Peatlands are fragile hydrological systems that are difficult to restore once disturbed.

2. IPCC Recommendations on Ireland's current Windfarm Strategy

2.1 Dúchas, the Heritage Service, must complete comprehensive national habitat and bird surveys of upland areas without delay with the aim of identifying all areas with a high conservation status that merit designation as Natural Heritage Areas (NHAs)/Special Areas of Conservation (SACs)/Special Protection Areas (SPAs).
There are a number of upland mountain ranges that have never been surveyed and therefore are under-represented in the national lists of wildlife designated sites (NHAs/SACs/SPAs). There are a number of cases where upland blanket bogs that merit designation as NHAs/SACs/SPAs have been damaged by windfarm developments, IPCC believe that, had these sites been designated appropriately the developments would not have been permitted.

2.2 Incentives for developers not to locate exclusively in upland areas
Under the present Alternative Energy Requirement (AER) schemes prospective renewable energy producers are invited to submit competing tenders for the sale of a predefined quota of electricity to the national grid. Bidders who pass technical and commercial evaluation and who submit the lowest prices for the sale of electricity are guaranteed sale for their output to ESB Power Contracting for a fixed period. IPCC believe that the competitive nature of the scheme compels producers to locate wind farms in upland areas so as to increase the economic viability of the proposal. We recommend that the Department of Public Enterprise undertake an immediate review of the AER schemes. This review should attempt to ensure that non-upland areas are made attractive for wind energy producers, planning considerations should also be taken into account within the schemes.

2.3 Comprehensive and Mandatory Environmental Impact Assessment (EIA)
Currently, there is no mandatory Environmental Impact Assessment for wind farm developments and there are some inconsistencies over the status of the biological importance of sites in recent An Bord Pleanála decisions. It is essential that all planning authorities explicitly recognise, on an equal footing, the ecological importance of sites in conjunction with visual amenities. IPCC feel that all wind farm proposals, irrespective of size should be subject to full and proper Environmental Impact Assessment Surveys under EU Directive 85/337/EEC.

These surveys must address, inter alia:

Upland Habitat Surveys
All upland areas scheduled for wind farm sites must be adequately surveyed for their habitat value. The scientific surveys carried out by EIAs are often of poor quality. Until such time that Dúchas carry out a national survey, all sites proposed for wind energy projects should be visited and surveyed by technical staff of Dúchas at the earliest possible time.

Bird Surveys
The Environmental Impact Assessment, should include a survey of the birds breeding and feeding within the impact area over a winter and summer season. During this period at least two winter and three summer visits should be completed. This is especially important because there has been no recent and comprehensive survey of upland breeding birds hence there are sites of potential conservation importance which have not been identified and are therefore not protected by the existing suite of statutory designations. Surveys will provide the minimum information required upon which to assess the conservation importance of the area and to determine whether or not the development is appropriate. Should the development then go ahead, this will also provide the basis for a monitoring programme.

2.4 A Necessity for Research Into Impacts and Mitigation
The surveys carried out during an EIA should function as baseline data for further monitoring should a development proceed. There is a need to carry out in-depth research into the effects of windfarms on upland ecology and from this, new technologies may be developed to minimise impacts as much as possible. The effectiveness of present methods used in minimising impacts also needs to be investigated. Dúchas should be directly involved in any such research. The effectiveness of present methods used in minimising impacts should also be determined through independent research. Long term ecological monitoring of existing windfarm sites should take place.

2.5 Mitigation
Should wind farm developments take place on peatlands the best available techniques must be insisted upon to ensure that impacts on the peatland are minimised.

2.6 Monitoring and Mitigation of Impacts of Windfarms on Birds
From the research completed to date, there is sufficient evidence to determine that wind farms do impact on birds, however further research over a longer period is required before the effects can be fully established and understood. Long term monitoring programmes should be implemented for a number of wind farm sites. This will help to inform decisions regarding the siting of future developments. In such cases, pre - construction baseline data on the birds should be collected over a 2-3 year period and a range of ecological variables should be monitored both during and post - construction. Long term monitoring programmes to investigate impacts such as bird mortality and disturbance effects, should also be introduced at a number of existing wind farm sites.

2.7 Review of Windfarm Planning Guidelines
Windfarms must not be permitted within or adjacent to sites with a high conservation importance that are designated or likely to be designated as Natural Heritage Areas (NHAs), Special Areas of Conservation (SACs) and Special Protection Areas (SPAs).
IPCC are aware of a number of proposals to locate windfarms within proposed NHAs/SACs. These developments must not be granted permission. The Department of the Environment Guidelines for planning authorities need to be re-drafted to clearly state the above and avoid further damage and threats to conservation worthy uplands.

2.8 Zoning land suitable for Wind Energy Projects
IPCC are pleased that the Minister for the Environment and Local Government and the Minister for Public Enterprise are implementing the recommendations made by the Renewable Energy Strategy Group in relation to spatial planning. At present a windfarm development takes on average 14 months to pass through the planning process. Local Governments are now proposing to identify areas within their counties as 'preferred', 'open to consideration', 'strategic', and 'no-go' for wind energy development. From this information maps will then be produced incorporating electrical network limitations, wind resource limitations. These will then be incorporated into county development plans (Renewable Energy Strategy Group 2000). Public consultation should be undertaken in relation to the production of these maps.

References

Department of the Environment 1996. Wind Farm Development ­ Guidelines for Planning Authorities. Stationery Office, Dublin.

Douglas, C. 1998. Blanket Bog Conservation. In: O'Leary, G. and Gormley, F. (eds.) 1998 Towards a Conservation Strategy for the Bogs of Ireland, pp205-222. IPCC, Dublin.

Galvin, P. 2001. BirdWatch Ireland Policy on Windfarms. BWI Policy 01-01.

Renewable Energy Strategy Group 2000. Strategy for Intensifying Wind Energy Deployment. Stationery Office, Dublin.

1996 Joint Policy statement by the Irish NGO's on Windfarm Developments